AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE

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AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE
SAFER GAMBLING CAMPAIGN DEVELOPMENT

AVOIDING BET REGRET
An overview of the campaign to date

December 2020

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AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE
FOREWORD

Gambling harms are best understood as matters of health and wellbeing – as a public health issue
demanding a ‘whole system’ public health response, across:
     •    Primary prevention - universal promotion of a safer environment
     •    Secondary prevention - selective intervention for those who may be ‘at risk’
     •    Tertiary prevention - direct support for those with gambling disorder or for those who may
          be directly affected
Recognition of gambling as a public health issue is relatively recent, and there is little experience
globally of well-evidenced interventions contributing to the prevention of the harms that can be
caused by gambling.

Whilst recognising that any campaign is only one of several factors influencing a target group, the Bet
Regret campaign has broken new ground in engaging ‘at risk’ groups, in this case frequent sports
bettors – a campaign developed in a systematic way following public heath campaign principles.

In this context – and in the broader spirit of transparency – this report documents the campaign to
date, explaining why it exists and how it came to fruition; what was done and why; what has
happened to date (impacts); and lessons that have been learned. It is hoped that the learning
reflected in this report will help to inform future campaigns to prevent gambling harms. Intended for
a broad audience, more detail in terms of research and data is available for specific academic
research purposes.

This campaign represents just one step on the broader journey to keep people safe from the harms
that can result from gambling. We, the Safer Gambling Campaign Board were encouraged by the
announcement on 8 December 2020 of a Review of the Gambling Act 2005, with wide terms of
reference, including a call for evidence around the relationship between sport and gambling to which
we hope our report will contribute1.

Many people have been involved in the development and implementation of the Bet Regret
campaign, without whose contributions and commitment it would not have happened. I would like
to thank: the team at GambleAware for making it happen; the communications agencies, consumer
research agencies and consultants who supported this; the many subject matter experts and other
stakeholders who gave valuable advice; and the gambling operators, broadcasters and online media
platforms that contributed funding and free media space; the Department of Digital, Culture, Media
and Sport (DCMS) for the initial impetus and ongoing support; and last but not least my fellow
members of the Safer Gambling Board.

Although we will be coming to an end of the two year project in Spring 2021, the learning from the
campaign will not be lost and will form the underpinning of further work by GambleAware as we
continue to tackle the need to prevent gambling harms.

Professor Sian M Griffiths – Chair, The Safer Gambling Board

1
 https://www.gov.uk/government/publications/review-of-the-gambling-act-2005-terms-of-reference-and-call-for-evidence/review-of-the-
gambling-act-2005-terms-of-reference-and-call-for-evidence

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AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE
INTRODUCTION

The designation of gambling as a public health issue in Great Britain is relatively recent2. Globally,
there is a little experience of well-evidenced campaigns aimed at preventing the harms that can be
caused by gambling. In this context, the Bet Regret campaign has broken new ground and has been
developed in a systematic way following broader public heath campaign principles:
       •     Robust, evidence-based, and built on a clear logic model
       •     Continuously measured
       •     Aiming to deliver positive impacts on behaviour, not just public information
The overall aim of the Bet Regret campaign is to help moderate the gambling behaviour of risky
sports bettors3, recognising that any campaign is only one of several factors influencing the target
group. Campaign objectives were more specifically defined as:
       •     Year One: To shift attitudes and provoke conversation amongst the target group on the
             moderation of sports betting, through the avoidance of impulsive, risky behaviours such as
             chasing losses in the heat of the moment (Broad audience of sports bettors)
       •     Year Two: To increase the numbers of risky sports bettors taking steps to cut down their
             gambling, both generally and by deploying specific moderation techniques and aids
             (Behaviour Change audience – more frequent bettors)

This report has been prepared by GambleAware on behalf of the independent Safer Gambling
Board. GambleAware advocates the application of a public health lens in addressing gambling harms,
and the delivery of the Bet Regret campaign is part of a broader strategy to prevent gambling harms
that will develop further over time. For example, a potential campaign specifically aimed at
preventing gambling harms amongst women is currently in development.

This report provides an overview of the key steps in the campaign’s development and
implementation, from initial political policy impetus and alignment of stakeholders (October 2016),
to the creation of a public health driven approach and capability, to the development and launch of
the first stage of the campaign (February 2019), and subsequent development and launch of the more
behaviourally focused second stage of the campaign (September 2020) and its initial results.

It covers a period impacted by the coronavirus pandemic, ongoing since March 2020. When we
started the project we could not have foreseen the impact of COVID-19 on sport and sports
betting, but we monitored the suspension of live sport in Spring 2020 and adapted the programme
by pushing back the start of the second stage of the campaign from Spring to September 2020.

The campaign has been extended beyond the proposed two years due to impacts of the coronavirus
outbreak. This extended period will end in Spring 2021, following further activity in February and
March 2021. This report will be updated, and next steps reviewed at that time.

2
    Action on gambling-related harms was added to the Public Health England remit in 2018.
3
    Currently defined as young men (16-34) who gamble 2 or more times a week, who bet online and who bet on football.

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AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE
BET REGRET CHRONOLOGY & REPORT COVERAGE

CHAPTER 1: Campaign pre-history, political and stakeholder context – Oct. 2016 to Jan. 2018
•   DCMS launched a ‘call for evidence’ on aspects of the gambling industry, including the impacts of gambling
    advertising (Oct. 2016).
•   Ministers voiced specific concerns relating to the weight of gambling advertising on TV around football.
•   In March 2017 DCMS requested proposals from gambling operators, broadcasters and other interested parties for
    a campaign encouraging ‘responsible behaviour’ to help balance commercial advertising.
•   There followed an extended process, part brokered by the Advertising Association which GambleAware joined, to
    align stakeholders around a single proposal on campaign aims, funding and delivery.
•   On 31 October 2017, based on the subsequent proposal, DCMS announced (for consultation) that GambleAware
    would lead the independent delivery of a campaign, funded but not guided by operators and broadcasters.
•   GambleAware Trustees supported the proposal on the explicit condition that the campaign governance followed a
    public health driven approach, and was independent of the gambling industry.

CHAPTER 2: Creating a public health driven approach and delivery capability – Feb. to June 2018
•   The Safer Gambling Board first met on 8 February, with terms of reference finalised in March.
•   In parallel GambleAware was asked to set about building the capability to deliver the campaign at pace, including an
    initial fast evidence review and process to brief, select and appoint relevant communications agencies (July 2018).

CHAPTER 3: Campaign development Stage 1, leading to ‘Bet Regret’ – Oct. 2018 to Feb. 2019
•   In part due to the initial timetable imposed, the initial agency proposals were not workable and a more thorough
    programme of consumer research and advice from subject matter experts was undertaken to refine the target
    group (Consumer Segmentation survey) and creative brief (Oct 2018).
•   Creative and media proposals were developed, and funding secured.
•   Two further stages of consumer research were undertaken to help select, test and refine the most effective
    approach.
•   The underpinning Logic Model for the campaign was also developed and agreed (November 2018).
•   Production of the various campaign materials was undertaken, and the campaign launched on 21 February 2019.

CHAPTER 4: Bet Regret campaign Stage 1 implementation and impacts – from Feb. 2019
•   Two main waves of advertising, Feb/ March and Sept/ Oct 2019 – TV plus digital media – plus near continuous
    digital activity; supplemented by a number of grassroots Bet Regret activations and an online partnership
    (LADBible).
•   Digital only Bet Regret activity continued through to August 2020, as the more behaviourally-focused second stage
    of the main campaign – originally planned for Spring 2020 – was delayed due to the coronavirus pandemic.
•   Regular measurement and reporting of campaign impact, attitudes and behaviour undertaken by Ipsos MORI, with a
    baseline measure taken in November 2018 (7 waves to date, ongoing).

CHAPTER 5: Campaign development Stage 2, leading to ‘Tap Out’ – Sept. 2019 to Aug. 2020
•   Development of the behaviourally-focused second stage of the campaign commenced, as planned, in September
•   A workshop helped generate a long list of behavioural ‘nudges’, which was then refined to a shortlist of four
    working with behavioural scientists and academic experts in the area (this was undertaken while Stage 1 was still
    running).
•   The top three were trialled in use by frequent bettors to test usefulness and impact (Ipsos MORI, Nov 2019).
•   Creative routes (initially three – based on the winning nudge) developed, tested and refined in consumer research.
•   Production and launch put back from Spring until Sept. 2020 due to coronavirus impacts.

CHAPTER 6: Stage 2 campaign implementation and initial impacts – from Sept. 2020, ongoing
•   ‘Tap out for time out and avoid Bet Regret’ was launched on TV, digital and radio on 8 September 2020, with TV
    running until the end of October – with a further wave planned for Feb/ March 2021.
•   Initial results from the Ipsos MORI tracking are included here.

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AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE
EXECUTIVE SUMMARY – KEY LEARNINGS OVERVIEW

Chapter 1: Campaign pre-history, political and stakeholder context – Oct. 2016 to Jan.
2018
Although the campaign is funded by donations from gambling operators, broadcasters and some
digital media channels great care was taken to follow public health campaign principles which were
delivered by an independent board in terms of governance and decision-making.

Initial impetus for the campaign, and the request to gambling operators and broadcasters to support
it, came from a broader review of gambling undertaken by DCMS, rather than from any specific
focus on public health – although gambling harms have subsequently become formally recognised in
public health terms and added to the PHE remit (initially for research).

A complex stakeholder ecosystem meant that the campaign necessarily had a long gestation period,
before even the formation of the Safer Gambling Board. A key learning point here is that in this
type of context creating the necessary alignment to be able to start to make a difference takes time,
persistence, a lot of engagement, listening and negotiation.

Chapter 2: Creating a public health driven approach and delivery capability – Feb. to
June 2018
The request that the Board proceed at pace – with the aim of launching in Autumn 2018 – was
understandable, but in retrospect did not allow time for consumer research, nor for as full a
consultation with subject matter experts as would have been desirable, to get to a validated strategy.
After initial agency pitches and creative recommendations, there was insufficient confidence and
alignment on a way forward. This related to fundamental concerns about the original brief – based
on setting limits – and it was agreed that a more thorough strategic process was needed. However,
the Board recognised the need to focus the campaign given limited budget and agreed to target the
largest at-risk group – young men betting on football.

This initial work (up to June 2018) produced many valuable learnings, in a relatively short time, about
what might - and might not - work. The decision was made to take a step back to build on this
work, to consult more broadly than time constraints had initially permitted, and undertake a
stepwise approach guided by several stages of research with the target group of younger male
bettors – still at pace but not constrained by a set deadline.

It was recognised that this was a difficult communications challenge, with no existing success models
to build on. Getting to an effective campaign solution, and alignment around it, would require a
more thorough and iterative process and it was decided to adjust the timetable to accommodate
more consultation with the target group.

Chapter 3: Campaign development Stage 1, leading to ‘Bet Regret’ – Oct. 2018 to Feb.
2019
Taking the time to allow for the more considered approach from July 2018 (albeit building on
valuable learnings from the deadline-driven process in February to June), was important in getting to
a well-validated approach, and alignment on it.

It allowed for a broad consultation with subject matter experts, but also enabled the move from the
theoretical to the practical by testing and refining approaches with the target group. Ultimately,
there is no substitute to listening and testing ideas with the target group in consumer research, in an

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AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE
iterative ‘test and refine’ (or reject) way – which takes time, and consequently was not feasible in the
initial stage of development.

Key learnings for ways to approach future stages of a campaign (unless there is strong existing
learning to build on) include realistic timings allowing for a more orderly process:
    •   Follow a stepwise process, and allow realistic timings
    •   Undertake a full scoping exercise gathering existing learnings, stakeholder and subject matter
        expert views (generally requiring 3-4 months minimum), and develop a protype Logic Model
        (possibly to be refined later) before moving to campaign development
    •   Work with a communications agency, take forward the key hypotheses relating to effective
        interventions and messages – and ways of engaging the target group with these – in a multi-
        stage programme of consumer research
    •   Regular ‘check ins’ on progress between the Campaign Director and Chair of the Board,
        between quarterly Board meetings
These learnings were applied successfully to the development of Stage 2 of this campaign, and also to
a potential campaign that is now in development specifically aimed at preventing gambling harms
amongst women

Chapter 4: Bet Regret campaign Stage 1 implementation and impacts – from Feb. 2019
The Bet Regret campaign achieved high levels of recognition and engagement, despite a budget
dwarfed by the total communications spend of gambling operators (representing a 2.8% share of
voice of total sports betting spend - source: Nielsen). The campaign has been monitored by Ipsos
Mori with 7 waves of the Tracking Study conducted pre and post each wave of activity.

With ‘in principle’ awareness of risks already high amongst regular sports bettors, the main shifts
observed were in fact closer to the behavioural end of the Logic Model – showing directional
increases in the number of bettors considering cutting down and decreases in numbers reporting
behaviours widely regarded as risky. It is significant that implicit warnings about the risks of betting
via the Bet Regret-inducing scenarios featured (when chasing losses, drinking, betting on things we
know little about, or when bored) have directly impacted on reported behaviour.

It reinforces a general learning that, while emotional engagement may be a necessary precondition to
behaviour change, behavioural response is also dependent on more concrete suggestions of what
people should do to help moderate their behaviour and reduce the risks of harms. This was
particularly important as research had shown that no one moderation technique was top of mind.

Having created the association between potentially risky betting behaviours and the (unwanted)
experience of Bet Regret, the platform was established for the next stage of the campaign, to
provide bettors with techniques to help them avoid it.

Chapter 5: Campaign development Stage 2, leading to ‘Tap Out’ – Sept. 2019 to Aug.
2020
The key learning here is that the process learnings from Chapters 2 and 3 (from the development of
Stage 1 of the campaign) are very valuable, with the development process for Stage 2 (the impacts of
COVID excepted) running smoothly – leading to the identification of the mental aid of ‘tapping out’
and closing your betting app, to create a pause before committing to a bet.

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AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE
Chapter 6: Stage 2 campaign implementation and initial impacts – from Sept. 2020,
ongoing
The Tap Out message has cut through and been clearly received, especially by those for whom it is
most relevant behaviourally as an aid to moderate and prevent harms – whether via literally tapping
out or simply prompting people to pause and reflect before making a bet. It is highly talkable and has
the potential to complement ‘Bet Regret’ by becoming a meme and useful mental aid amongst
bettors.

What is not clear at this point – a few weeks in – is whether it can be successfully embedded in
bettor’s routines as a regular, default behaviour. This is clearly the challenge and focus for the
refinement for communications for the next wave of activity in February/ March 2021 (guided by
further analysis and diagnostic research).

In encouraging more considered, less impulsive betting behaviours any campaign pits itself against
considerable pressures in the other direction across broadcast and social media. For example, ‘push’
messages in app, often focused on immediate, in-play betting opportunities, and increasingly
frictionless betting interfaces.

Effective prevention of gambling harms requires a coherent and co-ordinated whole systems
approach involving partnerships with other organisations to inform and educate, as well as
consideration of regulatory interventions and product safety and design requirements.

A legitimate question is how much any communications campaign can achieve in isolation. It is clear
that the Bet Regret campaign is only one part of a broader public health dynamic, preparing the
ground for behaviour change amongst those who gamble and across the whole gambling ecosystem.
This includes safer gambling commitments made by operators themselves (in terms of safer gambling
communication and tools), and likely regulatory action.

The Board is encouraged by the announcement on 8 December 2020 of a Review of the Gambling
Act 2005, with wide terms of reference, including a call for evidence around the relationship
between sport and gambling4.

4
 https://www.gov.uk/government/publications/review-of-the-gambling-act-2005-terms-of-reference-and-call-for-evidence/review-of-the-
gambling-act-2005-terms-of-reference-and-call-for-evidence

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AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE
CHAPTER 1: CAMPAIGN PRE-HISTORY, POLITICAL AND STAKEHOLDER
CONTEXT – OCT. 2016 TO JAN. 2018

The initial impetus for the campaign

In October 2016, the Department of Culture, Media and Sport (DCMS) launched a ‘call for
evidence’ on aspects of the gambling industry, including the impacts of gambling advertising.5

This was intended to “gather evidence to fully assess current rules and protocols in the gambling sector and
to help inform the government to make decisions on any necessary amendments to gambling regulation”. A
particular focus was fixed-odds betting terminals (FOBTs). However, “(E)vidence will also be sought on
measures to protect against gambling related harm including the impacts of gambling advertising and
whether the right regulations are currently in place to protect children and vulnerable people”.

On the same day, the Secretary of State for Culture, Media and Sport (Rt Hon Karen Bradley, MP)
gave evidence to the House of Commons Culture, Media and Sport Committee in relation to
gambling-related advertising and the possible impact on children. Her comments were widely
reported in the national media.

In December 2016, GambleAware published its response to the Government’s ‘call for evidence’.6 In
relation to gambling advertising they cited two research reports commissioned by GambleAware: a
critical research review of gambling advertising (Binde, 2014) and an investigation into the role of
social media (Miller, Krasodomski-Jones & Smith, 2016).

On 30 January 2017, Tracey Crouch, MP (Minister of State, DCMS) hosted a roundtable to discuss
gambling advertising with representatives from both the gambling and broadcast industries.
(GambleAware was not invited). In particular, the Minister raised concerns relating to the ubiquity of
gambling promotion around sports coverage (especially football) .

On 9 March 2017, in the light of an emerging consensus about the need for ‘stand-alone’ advertising
promoting responsible behaviour and/or warning of the risks associated with gambling that would
serve to provide some balance to the existing commercial advertising, GambleAware Trustees
discussed an invitation from DCMS to submit a ‘proposition’ about what the charity may think would
be an appropriate approach.7 GambleAware wrote to Tracey Crouch, MP setting out details of what
a GambleAware-led advertising campaign might look like.8

DCMS received separate responses from gambling industry trade bodies and broadcasters, as well as
GambleAware. They then requested that the various parties work together to align on a single
response. Helped by an independent consultant, the Advertising Association undertook to facilitate
this response, to cover approach, governance and funding.

On 15 August 2017, the Advertising Association wrote to Tracey Crouch with proposals for a major
responsible gambling advertising campaign, to run for two years with a budget of £5-7 million in each
year.9 The letter was also signed by representatives from the gambling industry, broadcasters and
GambleAware.

5
  https://www.gov.uk/government/news/government-calls-for-evidence-on-gaming-machines
6
  https://about.gambleaware.org/media/1361/gambleawares-submission-to-dcms-review-of-gaming-machines-2-december-2016.pdf
7
  GambleAware Board meeting on 9 March 2017 – agenda item 12
8
   Letter dated 13 March 2017

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AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE
GambleAware Trustees supported the proposal on the explicit condition that the campaign
governance followed a public health driven approach and decision-making was independent of the
gambling industry.

On the 31 October 2017, DCMS published the responses to its ‘call for evidence’ and the
Government’s proposals for consultation until 23 January 2018. The consultation reflected the
proposals made via the Advertising Association for a safer gambling campaign and noted:
“GambleAware will lead the campaign, ensuring the content is independently approved and meets the
campaign objectives. It intends to set up a Campaign Board and Delivery Unit, appointing an independent
chair of the Board and approving all campaign content. The Government welcomes the initiative by
broadcasters and the gambling industry to fund and work with GambleAware to deliver a major responsible
gambling advertising campaign.”10.

At the outset the aim of the campaign was defined as a) to raise public awareness of risks associated
with gambling and b) signposting to further advice and support where necessary. It was agreed that
the responsible gambling industry group, Senet, would continue to fund its existing ‘When The Fun
Stops Stop’ messaging and responsible gambling advertising work, but work to bring this in line with
the wider campaign11.

Formation of the Safer Gambling Board

On 15 November 2017, GambleAware wrote to all parties to advise them of the proposed
governance and delivery arrangements for the campaign. The first meeting of the Safer Gambling
Board was held on 8 February 2018, where terms of reference were discussed and subsequently
confirmed in March 2018.

The Board currently comprises12:
     •    As Chair, Professor Sian Griffiths, GambleAware Trustee: Associate Non Exec Director,
          Public Health England; Non-Exec Director Public Health Wales
     •    Sheila Mitchell, former Marketing Director, Public Health England
     •    Teresa Owen, Executive Director of Public Health, Betsi Cadwaladr University Health Board
     •    Professor Marcantonio Spada, GambleAware Trustee and Professor of Addictive Behaviours
          and Mental Health at London South Bank University
     •    Marc Etches, Chief Executive, GambleAware
     •    Department of Digital, Culture, Media and Sport representative

Professor Antony C. Moss, BSc (Hons), PhD, Professor of Addictive Behaviour Science and Director
of Education & Student Experience at the School of Applied Sciences, London South Bank University
acts as an academic adviser to the Board.

Bodies that originally proposed the campaign to Government and which are funding it in cash and in
kind are also present as observers – the Advertising Association, the Betting & Gaming Council,
Regulus Partners (an industry consultant) and commercial broadcasters (represented by Sky).

The terms of reference13 for the Board make clear that only full members of the Board exercise
voting rights, observers are updated regularly on campaign development but have no role in
decisions about the direction and content of the campaign.

10
   https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/655969/Consultation_on_proposals_for
_changes_to_Gaming_Machines_and_Social_Responsibility_Measures.pdf
11
    Senet has now been disbanded, and superseded by the Betting & Gaming Council; discussions on alignments are ongoing.
12
    2 original members withdrew in July 2018, with 3 new members added soon after
13
    https://about.gambleaware.org/media/1763/final-draft-terms-of-reference-14032018.pdf

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AVOIDING BET REGRET AN OVERVIEW OF THE CAMPAIGN TO DATE - BEGAMBLEAWARE
The Board has steered the subsequent development of strategy and implementation of the campaign,
based on an evidence-based, public health-driven approach.

During the development of the campaign the Board consulted an Advisory Panel, established to help
inform the Board’s decision-making as well as to provide confidence to all stakeholders. This panel
comprised members with lived experience of gambling harms, and representatives from faith leaders
(represented by CofE), GamCare, Camelot, Adfam and the Royal Society of Public Health.

GambleAware context

GambleAware14 is a wholly independent charity working to keep people in Great Britain safe from
gambling harms. Gambling harms are best understood as matters of health and wellbeing – as a
public health issue demanding a ‘whole system’ public health response, across:
        •    Primary prevention - universal promotion of a safer environment
        •    Secondary prevention - selective intervention for those who may be ‘at risk’
        •    Tertiary prevention - direct support for those with gambling disorder or for those who may
             be directly affected
Guided by this public health model, GambleAware commissions prevention and treatment services
in England, Scotland and Wales underpinned by research and evaluation – working to ensure
evidence-informed services are developed according to need within a robust and accountable
system, and that funding is allocated efficiently and independently.

Effective prevention of gambling harms requires a coherent and co-ordinated ‘whole systems
approach’ involving partnership with the NHS, public health agencies, local authorities, and voluntary
sector organisations. This will ensure appropriate referral routes and care pathways are in place for
individuals in need of support, including treatment, to receive the right intervention at the right time.

GambleAware plays an important role within this approach, guided by an independent and expert
Board of Trustees, the majority of whom work in the health sector. All work is undertaken within
an established range of governance processes and procedures, that ensure the industry has no
influence over any commissioning decisions (including those relating to the campaign covered in this
report).

The Safer Gambling Board operates within this broader GambleAware context.

14
     https://www.begambleaware.org/sites/default/files/2020-12/briefing-note-november-2020.pdf

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Chapter 1 – Learnings
The initial impetus for the campaign, and the request to gambling operators and broadcasters to
support it, came from a broader review of gambling undertaken by DCMS, rather than a specific
focus on public health – although gambling harms have subsequently become formally recognised
in public health terms and added to the PHE remit (initially for research).

Politically, gambling is a conflicted issue for any UK government – it is a legal activity, a matter of
personal choice and public enjoyment, which raises taxes, as well as generating important
revenues for sport and broadcasters. It operates in a relatively liberalised environment in terms
of marketing and communications (2005 Gambling Act), and participation is increasing online,
posing further regulatory challenges. In this environment the natural commercial drive of
gambling operators has led to high levels of advertising and promotion, not least around sport,
and especially football.

Historically, there has also been a tendency to frame gambling as a ‘responsibility’ issue – putting
the onus on individuals as well as gambling operators to behave responsibly, with responsibility
also put on operators to fund gambling treatment services. There has been a move towards more
proactively creating a safer environment for gamblers (e.g. limit setting tools and exclusion tools),
but the shift to a public health approach nevertheless challenged conventional thinking, especially
amongst the gambling industry – even though in this case the focus is about gambling safely to
help prevent harms, moderation rather than cessation.

There was also some mistrust amongst some industry stakeholders, with concerns that an
independent GambleAware-led campaign would potentially denigrate gambling and damage their
businesses commercially. In addition in 2018, there were competing agendas between different
gambling operators, with those with land-based operations and purely online operators being
represented by different trade organisations before the formation of a single trade body, the
Betting & Gaming Council, in 2019.

In this context, getting alignment around what is a voluntary campaign with an independent public
health approach, and a focus on behaviour moderation rather than just ‘responsibility’ or public
information, was challenging. The challenge was exacerbated by there being no pre-existing
success models for a campaign of this scope, anywhere in the world, to reference and build upon.
This helps explain the campaign’s necessarily extended gestation period.

A key learning here is that in this type of context creating the necessary alignment
to be in a position to start to make a difference takes time, a lot of engagement with
a wide variety of subject matter experts, listening and negotiation.

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CHAPTER 2: CREATING A PUBLIC HEALTH DRIVEN APPROACH AND DELIVERY

CAPABILITY – FEB. TO OCT. 2018

Setting the overall focus for the campaign

A focus on sports betting was supported by Gambling Commission data on gambling participation
(behind only lottery and scratch cards) and those experiencing or at risk of harms – and also the
intensity of operator marketing, advertising and promotional spend in this area.

Drawing on public health experience and expertise relating to campaigns in other areas, it was also
clear that to have meaningful impact with the budgets available, it would be important to focus on
those groups where risk of harms was most present – a broad public message about gambling risks
in general would be highly unlikely to deliver any meaningful public health impact, especially on a
relatively modest budget.

So upfront at the Safer Gambling Board’s first meeting on 8 February 2018 it was agreed that the
campaign would focus on younger male sports bettors, with a particular focus on those most at risk
in terms of frequency of betting and propensity to exhibit risky behaviours such as chasing losses15.

Looking ahead the Board hopes to extend gambling harm prevention to other audiences, with work
on the development of a campaign focused on women (especially those at risk from online gambling
online) well-advanced.

Building capability

It was only in February 2018 that detailed work on campaign strategy and building the capability to
develop and implement the campaign started. From DCMS the ambition was to launch activity by
Autumn 2018 (in part to align with the new football season), imposing challenging a timeline given of
a campaign that would be breaking new ground, that ultimately proved not to be feasible given the
multiple stages of consumer research and creative development required.

This went beyond the scope of existing GambleAware campaign activities, so additional internal
delivery capability had to be built, as well as brief and appoint relevant communications agencies, all
at some pace. This was initially done with existing internal resource, with the help of a strategic
consultant. In summary, the key steps here were:

     •     Brief an academic rapid literature review and expert view (Jan/Feb/March).
     •     Review and summarise relevant published data on gambling participation and risk of harms as
           support for a campaign brief (Feb/ March).
     •     Develop and agree an initial campaign brief with the Board (March/ April).
     •     Work with ISBA16 to identify a long list of potential lead communications agencies, with
           relevant public health campaign experience and no current gambling industry clients, and
           conduct ‘chemistry meetings’ with six agencies (Feb/ March).
     •     Brief a shortlist of three agencies (M&C Saatchi, Mother and 18 Feet & Rising) to pitch
           creative proposals (late April), with intermediate meetings in May and final pitches, including
           Board member attendance in early June.
     •     Agency (M&C Saatchi) appointed in late June.
     •     A media agency and agency to support grassroots activation were appointed later in the
           year, closer to launch.

15
  NatCen data shows that 83% of problem gamblers are male, and 60% aged under 45.
16
  ISBA (Incorporated Society of British Advertisers) is a leading trade body that includes help with agency/client relationships and agency
selection within their services to members.

                                                                                                                                         12
The initial agency brief (April 2018)

The brief developed from an analysis of available literature and data, and signed off by the Board, can
be summarised as: to reduce the incidence of younger male sports bettors betting more than they
can afford to lose, by being less impulsive in their behaviour and encouraging them to set limits.

 Extracts from the full agency brief (April 2018):

 Overall Policy Objective
 Preventive – to promote safer gambling behaviours and, in particular, reduce incidence of occasions where
 younger male sports bettors bet more than they can afford to lose.
 (NB. This campaign pays into and will support other more direct interventions – regulatory or voluntary –
 to set limits and help bettors do so via limit-setting tools….).

 Marketing Objectives (EAST framework – understand and address barriers to change)
 1.   Encourage sports bettors to become more mindful – and less impulsive – by setting limits on their
      spend, making it easy to do this (arguably the biggest barrier to overcome).
 2.   Frame setting limits as attractive, creating a positive emotional framing; e.g. benefits in terms of
      (alternative uses for) the money or time saved.
 3.   Make interventions timely, being present close to/ during gambling opportunities around live sport in a
      highly distinctive way, standing apart from industry activity (avoiding their ‘conventions’), capturing
      their attention through emotion, and developing consistent, long term ‘brand assets’ (e.g. THINK!, Talk
      to Frank, 5 a day).
 4.   Make it social – part of the younger male conversation, on and offline, create positive peer pressure.

 Target Audience
 ▪    Younger men aged 18-34 betting frequently around live sport – both on and offline.
 ▪    Typically betting 2+ times a week, often much more, with a range of bets, incl. In-play, with 2/3 or
      more apps/ accounts, sports fans but bet beyond what they support/watch.
 ▪    Not problem gamblers (yet), but at-risk and may have experienced one-off episodes when they have
      spent more than they could afford.

 The aim is to keep the campaign ‘aperture’ wide and be relevant to a broad audience of ordinary gamblers
 at risk to low-level gambling harms, not ‘people with problems’ (= not me).

 Our Strategy – in summary
 To reduce the incidence of younger male sports bettors betting more than they can afford to lose, by being
 less impulsive in their behaviour and encouraging them to set limits.

 We will do this by making setting limits easy (simple, specific action), attractive (positive life benefits),
 timely (close to the gambling moment), and social. (Adding impact by encouraging operators to come on
 board, with timely ‘set limits’ prompts within their comms and apps.)

 In terms of executional approach, we will be emotionally stimulating (prompting self-appraisal, not simply
 delivering information), personally relevant, highly distinctive (standing apart from, not joining in with,
 industry activity), anchored by ‘safer gambling’ brand assets.

 Watch Outs
 ▪    There is no set ‘limit’, it will vary by personal circumstance. But thought should be given to developing
      ‘rules of thumb’ to help bettors set their own limits.
 ▪    We should not foster stigma or negative perceptions of people who experience gambling harms
      (counterproductive).
 ▪    Shock tactics or an over-serious or bleak tone unlikely to connect (activates ‘othering’) as long as it
      doesn’t minimise risk.
 ▪    Unintended consequences – inadvertently making gambling more attractive to our target audience or
      others seeing communications around live sport (e.g. young adolescents).

                                                                                                                  13
A detailed background briefing document was provided, summarising available evidence and insight,
and also a number of supporting documents in their entirety:
    •   The Gambling Commission’s latest annual report (February 2018): ‘Gambling participation in
        2017: behaviour, awareness and attitudes’ (plus technical annex)
    •   Gambling behaviour in Great Britain in 2015: Evidence from England, Scotland and Wales;
        prepared for the Gambling Commission by NatCen; August 2017
    •   Future Thinking: Responsible Gambling Campaign Development; November 2016
    •   Revealing Reality: Responsible Gambling: Collaborative Innovation Identifying good practice
        and inspiring change; 2017 (plus annex documents)
    •   Expert View - Responsible gambling public education campaign for Great Britain: A brief
        scoping review; prepared for GambleAware by Alexander Blaszczynski PhD & Sally
        Gainsbury PhD, Gambling Treatment and Research Clinic Science Faculty, Brain and Mind
        Centre, School of Psychology, The University of Sydney, January 2018
    •   Expert View on Influencing Gambling Behaviour from a Behavioural Science Perspective;
        Communications Science Group; Richard Chataway and Gonzalo Lopez Castellaro (with
        advice from Dr Mark Griffiths, Professor of Behavioural Addiction, Nottingham Trent
        University); March 2018
    •   Report on Senet Group Campaign Evaluation; October 2017

June 2018 – a false start

The Board was split in terms of response to the three creative pitches. At this point, there was
some questioning on the original brief given to the agencies – especially from some members with
an academic background – despite this having been signed off by the whole Board in advance. As
covered later, the brief was subsequently revised.

The creative proposals initially favoured by the majority was from M&C Saatchi (summarised below)
and built strongly on brief and public health campaign learnings, laying down a clear guideline to help
frequent bettors moderate their behaviour – ‘Stop at 3 in a row’, analogous to ‘5 a Day’ for instance:

This had researched well with the target audience (in pilot agency research), but in broader
consultation raised fundamental concerns (relating to the initial brief as much as creative proposals):
    •   It risks normalising that ‘3’ is acceptable, and indeed encourages lighter bettors to bet more.
    •   Whatever the chosen number, there is no safe level that the academic and health
        community could align around based on ‘the science’, in the way that messages like ‘5 a Day’
        or limits for weekly units of alcohol, although approximate, could be endorsed.
    •   Any challenge (explicit or implicit) to ‘stick to limits’ risks unintended consequences amongst
        some risk-taking young males.

                                                                                                     14
For these reasons it was decided not to proceed with proposed approach, but to appoint M&C
Saatchi on the basis of their strong public health campaign experience – initially on a project basis –
to work with the Board on a refined strategy (and Logic Model), and execution of it. Soon after this
a dedicated Campaign Director was added to the GambleAware delivery team.

 Chapter 2 – Learnings
 This initial work produced many valuable learnings in a relatively short time about
 what might - and might not - work. The decision was made to take a step back to
 build on this work, to consult more broadly than time constraints had initially
 permitted, and undertake a stepwise approach guided by a number of stages of
 research with the target group of younger male bettors – still at pace but not
 constrained by a set deadline.

 It was recognised that this was a difficult communications challenge, with no existing success
 models to build directly on. Getting to an effective campaign solution, and alignment around it,
 would require a thorough and iterative process.

 The desire to proceed at pace was understandable, but had not allowed time for consumer
 research, or as full a consultation with subject matter experts as would have been desirable to
 get to the right strategy.

 There was also a major challenge in terms of aligning stakeholders – and indeed different views
 on the campaign that was subsequently developed still exist and are intrinsically hard to fully
 resolve. The ‘North Star’ for all decisions remains a public health approach, and how the bettor
 target audience responds.

 For instance, those with hands on public health campaign experience often having rather different
 views on solutions from those in academia. Some of those in academia operate explicitly or
 implicitly on a ‘tobacco control’ model for public health issues, with a ‘playbook’ that works
 towards high levels of regulatory restriction, even prohibition, and precludes any industry
 engagement however arms-length. These were issues outside of the Board’s immediate scope,
 and while gambling operators and broadcasters have no involvement in campaign direction and
 decision-making, some engagement is necessary – not least because they are currently the only
 significant source of campaign funding.

 The self-imposed requirement to stay independent of gambling operators presents its own
 challenges, as they obviously play an important part in creating a safer gambling environment via
 their actions and communications around delivery of their products (in app, online, in physical
 locations, in their media communications).

 Creating alignment between the independent Bet Regret campaign and operator safer gambling
 activities remains an area where progress has been slow.

                                                                                                     15
CHAPTER 3: CAMPAIGN DEVELOPMENT STAGE 1, LEADING TO ‘BET REGRET’ –
OCT. 2018 TO FEB. 2019

From July 2018 – refining the strategy

A number of steps were undertaken, to some extent in parallel, on the journey to a refined brief:
    •   Consultation meeting with a broad-based advisory panel, including service users, GamCare,
        Church of England, Royal Society of Public Health, ISBA and gambling operators (July 2018).
    •   Meetings with a number of subject matter experts, including academics who have worked with
        DrinkAware on analogous communications issues (July – Sept. 2018).
    •   A major segmentation study with over 2000 frequent male gamblers (YouGov – Sept. 2018).
    •   A first stage of consumer research using alternative strategic concepts to explore the best
        way to communicate with frequent gamblers, to prompt them to self-reflect and ultimately
        moderate their gambling behaviour (The Nursery – 4 focus groups – Sept. 2018).

YouGov/GambleAware Frequent Gambler Segmentation Study

This study explored the behaviours, attitudes and profile of frequent male bettors in some depth,
providing valuable insights that helped guide the development of the campaign strategy.

It comprised a quantitative survey of 2,097 men aged 16-45 in the UK who have gambled (bet online
or in person on sports, or online casinos) in the last four weeks. Fieldwork was undertaken between
the 17 August and 5 September 2018, with figures weighted to be representative of the UK male
gambling population by age, region and social grade.

An important part of the analysis was a segmentation of frequent bettors based on gambling
attitudes, perceptions and behaviours. Six segments were identified following a factor analysis to
identify key discriminating variables, then a cluster analysis of respondents based on these variables.

Three of these segments (comprising 31% of the total sample) were identified as a key focus for any
intervention, comprising 42% of all gambling 3+ times a week, and 87% of those scoring as high or
medium risk based on PGSI problem gambling indicators, with reasonable numbers expressing
readiness to cut down:
•   Segment A (10%): Gamble more than others to relax and escape from the stresses of life –
    currently bet frequently, often exhibiting risky behaviours, such as chasing losses (High Risk).
•   Segment B (10%): Tend to struggle with gambling as they often do with other things in their
    life – low ability to delay gratification (Higher Risk).
•   Segment C (12%): Regular bettors across sports, more than others seeing it as a test of their
    knowledge and skill – but still displaying sometimes risky behaviours (Medium Risk).
There is a high incidence of higher risk gamblers in Segments A-C: 100% of Segment A are in
medium or high risk bands (derived from PGSI indicators), 97% of Segment B, 24% of Segment C.

Related to this they are much more frequent gamblers: 74% of Segment A bet 3 or more days a
week, 50% of Segment B, 67% of Segment C.

Segments A and B are characterised by very low scores on ability to delay gratification (i.e. strong
bias to impulsive behaviours generally) – and tend to score low on self-efficacy (i.e. ability to set and
stick to a plan of action). Both segments show a strong bias to low mental well-being on the Short
Warwick-Edinburgh Mental Wellbeing Scale. They are also the segments most likely to be smokers.

                                                                                                       16
47% of Segment A agree that ‘Sometimes I think I should cut down my gambling’, rising to 80%
amongst Segment B (33% amongst Segment C).

Segments D, E, F are lower risk, being currently more moderate and controlled in their behaviours,
but remain important as a prevention audience (problem gambling is often episodic, with episodes of
excessive and harmful gambling triggered by specific circumstances or life events):
•    Segment D (23%): Regular but more moderate bettors – some risky behaviours but, with
     reasonably high self-efficacy, generally in control of their gambling and finances.
•    Segment E (24%): More occasional bettors, mainly on football, mainly for fun – low risk of
     suffering gambling harms based on both behaviour and personality.
•    Segment F (21%): Least frequent and lowest risk group, happy to dabble occasionally with no
     concerns about their gambling.
All six segments have been profiled in detail in the full report.

Insight to build upon

This came from both exploratory research with the target audience (The Nursery – Focus groups –
September 2018) and meetings with subject matter experts, with the inputs from Professor Antony
Moss, building on his work with DrinkAware17.

The Nursery research report concluded:
     1. Finding a universal truth for betting behaviour feels hard to do – (for instance) one man’s ‘mug
        bet’ is another’s big opportunity
     2. But there do seem to be universal emotions experienced by everyone on their betting journey
     3. We believe that the potential lies in bets that you kick yourself for – rather than the bets
        (that could be rationalised as simply) bad luck or a long shot
     4. This needs to be expressed appropriately: so gamblers do not feel lectured – adult to adult,
        rather than parent to child
The opportunity for preventative intervention resides in helping to cut out the ill-considered, impulsive
bets that people make in the heat of the moment – often fuelled by loss chasing behaviour, boredom,
or alcohol. The bets that people instinctively know that they really should have made, and kick
themselves for, the moment that they have made them.

17Professor Antony C. Moss, BSc (Hons), PhD, Professor of Addictive Behaviour Science and Director of Education &
Student Experience at the School of Applied Sciences, London South Bank University

                                                                                                                    17
Experts in counselling those with compulsive disorders emphasised the importance of stimulating
self-reflection to help develop self-awareness in predisposing people to self-regulate their
behaviours. They proposed the ‘Socratic approach’ as a proven way of engaging those potentially
risky betting behaviours:

Creative development – from October 2018

This insight led to a brief for creative development summarised as follows in M&C Saatchi’s three
Box format:

A number of creative routes were developed from this brief and tested and refined via two further
stages of qualitative research with the target group (The Nursery - Focus groups – November 2018
and February 2019).

It was from this that the idea of ‘Bet Regret’ was developed and validated, through a
range of creative executions, bringing to life the universal feeling of regret we all get
the moment we make an ill-considered bet.

This was brought to life in situations where impulsive, ill-considered bets are most likely to be made
leading to the experience of Bet Regret:

    •   When chasing losses
    •   When drinking
    •   When betting on things we know little about
    •   When bored

                                                                                                    18
Research showed that:
                 •       The idea of Bet Regret was easily understood
                 •       ‘The bet you wish you had not made’
                 •       The situations portrayed were realistic and relatable in terms of familiar occasions when ill-
                         considered bets can be made

In parallel with this process and subsequent production of campaign materials, the challenging
process of securing funding was commenced and media plans developed. Broadcasters donated a
substantial proportion of the media buy in kind (as airtime, but guided by our independent media
planning process) meeting their commitment to provide £1.6m media inventory each year, with
Google promising $1m although only £400,000 was subsequently committed.
Creative and media details are provided in the next Chapter.

Anchoring our campaign strategy via a clear Logic Model (November 2018)

The Board was clear from the outset that the overall public health objective that the campaign pays
into is to help moderate the gambling behaviour of risky sports bettors18, recognising that any
campaign is only one of several factors influencing the target group.

Specific Campaign objectives were formalised as:
                 •       Year One: To shift attitudes and provoke conversation amongst the target group on the
                         moderation of sports betting, through the avoidance of impulsive, risky behaviours such as
                         chasing losses in the heat of the moment (Broad audience).
                 •       Year Two: To increase the numbers of risky sports bettors taking steps to cut down their
                         gambling, both generally and by deploying specific moderation techniques and aids
                         (Behaviour Change audience – more frequent bettors).
In November 2018, this was formalised in an explicit Logic Model to help guide the development of
the campaign, and provide a framework for measurement of campaign impacts over time:

                      BET REGRET LOGIC MODEL

                      Pre Contemplation             Contemplation               Preparation                   Action               Maintenance
     Sports Bettors

                                                                               Increase readiness to
                      Increase knowledge of risky    Build self awareness &
                                                                              change & knowledge of    Taking action to moderate    Sticking with it
                           betting behaviour        encourage conversations
                                                                                 how to cut down

This crystallised the thinking that had informed our approach since the project commenced in
February.

18   Currently defined as young men (16-34) who gamble 2 or more times a week, who bet online and who bet on football.

                                                                                                                                                       19
Related key performance indicators were:

Attitudinal/ Awareness – KPIs

                                        •       Increase in consideration of steps to moderate my betting
                                        •       Increase in ‘with more and more opportunities and prompts to bet, you have to take more
                                                care to stay in control of your betting’
                                        •       Increase in thinking more about my betting and learning from my mistakes
                                        •       Increase in awareness of the negatives of impulsive bets
                                        •       Increase in conversations about moderation of gambling (generally, yours, others)
                                        •       Media coverage/ social listening around moderation of betting/campaign themes

Behavioural

                                        •       Increase in numbers making efforts to reduce their betting
                                        •       Increase in uptake of moderation techniques (both personal and external help) – both
                                                reported via research and operator data
                                        •       Increase in ‘cutting out more impulsive, less considered bets that I shouldn’t have made’
                                        •       Uptake of any visibility/ moderation tool we develop

Ipsos MORI Campaign Tracking

The rigorous measurement of campaign impact – with measures relating to the various elements of
the Logic Model – is a central plank of a public health approach. Regular measurement and reporting
of campaign impact, attitudes and behaviour is undertaken by Ipsos MORI, with a baseline measure
taken in November 2018 (7 waves to date, ongoing).

The overall design of the survey in terms of sample design and core questions has remained
consistent to maintain comparability in terms of measuring trends and the impacts of specific
elements of campaign activity – although there have obviously been some questionnaire changes
relating to the evolution of campaign activity over the past two years.

The key attitudinal and behavioural measures and questions asked are summarised overleaf19:

                                         Year 1-2                                                                                                                                                       Year 2-5

                                         Pre Contemplation                       Contemplation                         Preparation                               Action                    Maintenance

                                            Increase knowledge of risky      Build self awareness & encourage    Increase readiness to change &
Message Task

                                                                                                                                                        Taking action to moderate           Sticking with it
                                                 betting behaviour                      conversations            knowledge of how to cut down

                                                You’ll BetRegret it                                             Tap out for timeout and avoid Bet   Tap out for timeout and avoid Bet
                                                                                    You’ll BetRegret it                                                                                          TBD
                                                                                                                              Regret                              Regret

                                                           Key audience: Campaign audience                                    Key audience: Behaviour change audience

                                                                             • I am thinking more about how                                          • I try to close or ‘tap out’ or my
                                        • With more and more                   much I gamble or bet than I                                             betting app and pause before
                                          opportunities to gamble, it’s        used to (Q8)                                                            deciding whether to place a
                                          easy to get drawn in to make                                                                                 bet (Q8)
                                                                             • I sometimes make bets I know     • I sometimes I think I should
                                          impulsive bets (Q9)                                                                                        • I have recently cut down my
                                                                               I shouldn’t (Q8)                   cut down my gambling (Q7)
   Attitudinal & Behavioural measures

                                        • It’s now so quick and easy to      • I sometimes make impulsive
                                                                                                                                                       gambling (Q7)
                                          make bets on a mobile phone,                                          • I intend to cut down my            • I am actually changing my
                                                                               bets in the heat of the            gambling in the near future
                                          it’s important to take care to                                                                               gambling habits to cut down or
                                                                               moment (Q8)                        (Q7)
                                          avoid bets you regret the                                                                                    stop (Q7)
                                          moment you make them (Q9)          • Sometimes I make bets that I     • If I wanted to cut down my
                                                                               regret the moment that I have                                         • I close or “tap out” of my
                                        • If you gamble or bet it’s really     made them, even before I
                                                                                                                  gambling in the future I would
                                                                                                                                                       betting app and pause before
                                          important that it does not                                              close or “tap out” of my
                                                                               know whether I’ve lost or not                                           deciding whether to place a               TBD
                                          interfere with your job or other                                        betting app and pause before
                                                                               (Q8)                                                                    bet to cut down the amount of
                                          day-to-day commitments (Q9)                                             deciding whether to place a
                                                                                                                                                       gambling I do (Q31a)
      • I would know the early       • Have been spoken to about                                                  bet to cut down the amount of
                                       spending too much time or                                                  gambling I do (Q31b)               • Reduction in risky gambling
        warning signs that someone                                                                                                                     behaviour: Bored / Chasing /
        might be gambling or betting   money gambling or betting • I know how to cut down my
                                                                                                                                                       Sport you don’t know (Q4)
        too much (Q8)                  (Q11b)                      gambling if I want to (Q7)
                                     • Have spoken to somebody,                                                                                      • Reduction in money spent on
      • I am aware of the harms of                                                                                                                     gambling compared to 3/12
        gambling and betting more      even jokingly, about them
                                                                                                                                                       months (Q5)
        than I can afford (Q8)         spending too much time or
                                       money gambling or betting                                                                                     • I make less bets I regret than
19
   Those highlighted in red were added (Q11a) subsequently from Wave 6 to help measure                                                              thepreviously
                                                                                                                                                        specific(Q7)
                                                                                                                                                                  impacts of ‘Tap Out’.

                                                                                                                                                                                                                   20
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